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HMRC internal manual

Compliance Handbook

How to do a compliance check: information powers: third party notice: partnerships: notice to a partner whose tax position is being checked, to check one other partner

When you give a notice to a partner, whose tax position is being checked, to check the tax position of one other partner in their capacity as a partner, see CH23720.

  • The notice you issue is a combined taxpayer (for the recipient partner) and third party notice (for the other partner). SEES Forms and Letters contains a combined notice - IIP22.
  • Your notice must name the other partner.
  • You do not need to give a copy of your notice to the named partner.
  • You do not need approval from the named partner.
  • You must ensure that the conditions for a taxpayer notice, see CH23520, are met in relation to the recipient of your notice.
  • The recipient partner has taxpayer appeal rights against the notice as it relates to their tax position and the tax position of the named partner.
  • If you seek the tribunal’s approval you do not need to give a summary of your reasons to either partner although you may if you consider it appropriate. You should consider carefully and respond positively to any request by a partner for a summary of reasons, provided that doing so will not jeopardise your check.